11th Circuit Offers Witty Take on 'The Case of the Polite Bank Robber'
"Of course, there's no such thing as a good bank robbery," the appellate panel wrote. "But from the perspective of the Sentencing Guidelines, there are certainly less bad ones."
November 27, 2019 at 04:22 PM
4 minute read
The U.S. Court of Appeals for the Eleventh Circuit's wit and writing style were on display, as the court entered sleuth mode to rule on a case involving an unusually courteous bank robber.
Its unsigned opinion came from a panel of Circuit Judges Robin S. Rosenbaum and Gerald B. Tjoflat, with Senior U.S. District Judge William H. Pauley III of the Southern District of New York, sitting by special designation.
The court had to decide whether the robber's conduct and language was threatening enough to justify a sentence enhancement.
It wasn't. And in the end, the panel vacated the defendant's two concurrent 46-month sentences from the district court.
"If this were an 'Encyclopedia Brown' mystery, it might be called The Case of the Polite Bank Robber," the opinion began.
The court explained that defendant Roberto Arturo Perez had taken no weapons into the Chase bank he robbed and into the Wells Fargo he attempted to rob in the space of one week in March 2017. There, he presented a note to bank tellers with instructions that included the words "please" and "thank you," and concluded with, "Press the alarm after I walk out. I have kids to feed. Thanks."
Perez "bargained pleasantly" with one teller for $5,000, according to the ruling, and was caught after allowing another to leave the counter mid-robbery, when another teller called for help. Perez pleaded guilty to robbery and attempted robbery without a plea agreement.
"Of course, there's no such thing as a good bank robbery," the panel wrote. "But from the perspective of the Sentencing Guidelines, there are certainly less bad ones."
This was one such case, the judges found, because although every robbery implies a threat of some sort, guidelines say defendants who used implicit or explicit threats of death in their crimes should be punished more harshly.
Senior U.S. District Judge James Lawrence King had found Perez's behavior warranted a threat-of-death enhancement, concluding a reasonable person would have feared for their life during the robberies.
The Eleventh Circuit disagreed, pointing out that Perez wore no disguise, made no suggestions of a weapon and made no threatening gestures.
"To the contrary, the evidence suggests that Perez's overall conduct would have somewhat mitigated a reasonable victim's fear of harm," the opinion said. "And his statement that he had 'kids to feed' also likely softened the impact of the demand, as it suggested that he was not devoid of empathy."
The 46-month sentence was on the low end of the enhancement spectrum, and the lower court did concede that the defendant's note "has a sense of overall threatening, and yet, it has a blandness to it … a plea for help for his kids," according to the opinion.
The state agreed with Perez's argument that the district court applied the wrong legal standard for a threat-of-death enhancement, but the panel said it nevertheless had a duty to decide independently. Alissa del Riego of Podhurst Orseck in Miami was appointed as an amicus lawyer to defend the judgment.
Del Reigo said it was an honor to be appointed to handle what she described as a tough issue.
"Both the appellant Mr. Perez and the government agreed that the application of the sentencing enhancement to Mr. Perez's sentence, given the record before the district court, was inappropriate," del Riego said. "I think it is generally beneficial to have an advocate with a different point of view to ensure every angle of the issue is explored, and I hope my service provided that benefit to the Court in this case."
Assistant Federal Public Defender Katherine Carmon in Miami represents the defendant. She did not respond to a request for comment by deadline. Jessica Kahn Obenauf prosecuted the case for the U.S. Attorney's Office in Miami, which declined to comment.
Perez's case was remanded for resentencing.
|Read the ruling:
Read more:
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllRogge Dunn Represents Florida Trucking Firm in Civil RICO Suit Against Worldwide Express
4 minute readTrending Stories
- 1Call for Nominations: Elite Trial Lawyers 2025
- 2Senate Judiciary Dems Release Report on Supreme Court Ethics
- 3Senate Confirms Last 2 of Biden's California Judicial Nominees
- 4Morrison & Foerster Doles Out Year-End and Special Bonuses, Raises Base Compensation for Associates
- 5Tom Girardi to Surrender to Federal Authorities on Jan. 7
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250